Cookies Policy

This Privacy Policy sets outhow we,naomitamayama.com,collect, store and use information about you when you use or interact with our website,http:www.naomitamayama.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 01/05/2018.

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not completein and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: Naomi Tamayama

How we collect or obtain information about you:

when you provide it to us (e.g. by contacting us, registering for live events that we promote for MOBE, placing orders for products and services we promote for 3rd parties (Amazon, Click Funnels, Fiverr, and Mobe), and signing up to our newsletter/

from your use of our website, using cookies and similar technologies, and

from third parties (Amazon, Aweber, Click Funnels, Fiverr, Internet Business School Leadpages, and Mobe).

Information we collect: Name, Contact details, Payment Information eg your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type),information about how you use our website (e.g. which pages you have viewed,] [the time when you view them and what you clicked on,and the geographical location from which you accessed our website (based on your IP address).

How we use your information: for administrative and business purposes (particularly to contact you, to process orders, to improve our business and website, to advertise our goods and services and if consent has been given to advertise selected 3rd party products and services (Amazon, Aweber, Click Funnels, Fiverr, Internet Business School Leadpages, and Mobe). To analyse your use of our website,and in connection with our legal rights and obligations.

Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers,to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights and when you have registered or purchased any third-party event, service or products (from Amazon, Aweber, Click Funnels, Fiverr, Internet Business School Leadpages, and Mobe).

Do we sell your information to third parties (other than in the course of a business sale or purchaseor similar event):No

How long we retain your information: for no longer than necessary, taking into account any legal obligationswe have (e.g. to maintain records for tax purposes),any other legal basis we have for using your information (e.g. your consent,performanceof a contract with you or our legitimate interests as a business)For specific retention periods in relation to certain information which we collect from you, please see themain section below entitled How long we retain your information.

How we secure your information: using appropriate technical and organisational measures such asstoring your information on secure servers based in USA,encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.

Transfers of your information outside the European Economic Area: Data is stored in USA on secure servers. We will only transfer your information to another location if we are required to do so by LAW. We will ensure appropriate safeguards are in place data is collected and stored via a third party AWEBER which have self-certified themselves as compliant with theEU-U.S. Privacy Shield.

Use of automated decision making and profiling: we do useautomated decision making andprofiling. We use Facebook Targeting cookie to enable us to target the people that are most likely to have an interest in the products and services that we promote and google analytics to gain information on the content we create and how relevant it is to our audience and to generate a general profile of the people who would be most interested in the products and services that we promote.

Your rights in relation to your information

to access your information and to receive information about its use

to have your information corrected and/or completed

to have your information deleted

to restrict the use of your information

to receive your information in a portable format

to object to the use of your information

to withdraw your consent to the use of your information

not to have significant decisions made about you based solely on automated processing of your information, including profiling

to complain to a supervisory authority

Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Information we collect when you visit our website

Web server log information

We use a third Partyserver to host our websitewww.naomitamayama.com called A2 Hosting, the privacy policy of which is available here: https://www.a2hosting.co.uk/about/policies#Privacy-PolicyOur website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed,information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website),and your browser version and operating system.

Use of website server log information for IT security purposes

We do not access log data from our website serverour third-party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and othercyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing:compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).Legal obligation:we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing:our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interests: we and our third-party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential,functional, analytical and targetingcookies. For further information on how we use cookies, please see our cookies policy which is available here: http://www.naomitamayama.com/cookiespolicy

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit aseor see our cookies policy.

Information we collect when you contact us

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (suchas your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing:ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract, or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use third-party email providers to store emails you send us. Our third-party email provider are

Fastmail located in USA and their privacy policy is available here:https://www.fastmail.com/about/privacy.html

Gmail located in USA and their privacy policy is available here: https://policies.google.com/privacy

We use technologies such as web beacons (small graphic files)] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click-throughrates, which our emails achieve. We will only use web beacons and insert any other tracking technologies you use in our emails if you have consented to us doing so.

Contact form

When you contact us using our contact form, we collectip address, name and email. We also collect any other information you provide to us when you complete the contact form.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing:ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract, or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored outside the European Economic Area on our third-party email provider’sservers in USAwhere our third-party provider stores your emails. Our third party email is Fastmail located in USA. Their privacy policy is available herehttps://www.fastmail.com/about/privacy.html

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

We do not record phone calls.

Legal basis for processing:ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation)Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract, or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing:ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation)Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

E-Newsletter

When you sign up for our e-newsletter on our websiteor opt to receivenews, offersand information on how to build and promote an online business from us by filling in the from on the website to sign up to the mailing list by entering your name and email address and clicking subscribe.

Legal basis for processing:yourconsent (Article 6(1)(a) of the General Data Protection Regulation).Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third-party service to send out our e-newsletter and administer our mailing list, Aweber. Their privacy policy is available here: https://www.aweber.com/privacy.htm

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third-party mailing list provider’s servers inthe USA. [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

When you place an order for goods or services on our website, we collect; name, email, telephone number, billing address, and shipping address.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing:necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.[1]

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions].

Third Party Products and Services

Mobe live events and 21 step training where; name, email, telephone number are recorded in order to deliver the service. This data is stored inour third-party email service Aweber based in USA. . Their privacy policy is available here: https://www.aweber.com/privacy.htm

Products and services advertised on our site that isthird-party promotions. All sales of products for the following companies will be taken by these companies and the only data recorded for Third-Party Products are;

Legal basis for processing:necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

On registering for third-party products and services that we promote. You will be offered the opportunity to receive marketing information from Naomitamayama.com. To receive marketing from us you will have to authorise this by clicking on the options to receive marketing information from us.

You are able to opt out of receiving this information at any time by clicking on the opt-out button at the bottom of any emails or contacting us via our contact form to request removal of your data from the database.

Our similar goods and services

Youcan opt-out to receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by clicking on opt-out on text messages and email communications, by ticking a box to opt-in when registering or buying a product/serviceor emailing us on support@naomitamayama.com.

We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

Transfer and storage of your information

We use a third-party service to administer our mailing list, Aweber.

Information you submit to subscribe for our e-newsletter will be stored outsidethe European Economic Area on our third-party mailing list provider’s servers inUSA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files)] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click-throughrates, which our emails achieve. We will only use web beacons and insert any other tracking technologies you use in our emails if you have consented to us doing so.

Our goods and services

You canopt-in, to receiving marketing communications from us in relation to our goods and services by email, and text message, orby ticking a box indicating that you would like to receive such communications.

We will send you marketing communications in relation to our goods and services onlyif you opt-in to receive them.

Legal basis for processing:consent (Article 6(1)(a) of the General Data Protection Regulation).Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third-party service to send out our e-newsletter and administer our mailing list, Aweber. Their privacy policy is available here: https://www.aweber.com/privacy.htm

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the USA. [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files)] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click-throughrates, which our emails achieve. We will only use web beacons and insert any other tracking technologies you use in our emails if you have consented to us doing so.

Third party goods and services

In addition to receiving information about our products and servicesyou can opt-in to receiving marketing communications from us in relation third party goods and services by email, text message, and ticking a box indicating that you would like to receive such communications.

Legal basis for processing:consent (Article 6(1)(a) of the General Data Protection Regulation).Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third-party service to administer our mailing list, Aweber.

Information you submit to subscribe for our e-newsletter will be stored outsidethe European Economic Area on our third-party mailing list provider’s servers inUSA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files)] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click-throughrates, which our emails achieve. We will only use web beacons and insert any other tracking technologies you use in our emails if you have consented to us doing so.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include; We Sell Good Traffic, We Sell Clicks or Mobe.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing:necessary to perform a contract, or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing:consent (Article 6(1)(a) of the General Data Protection Regulation).Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing:our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service)we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such asthe electoral register, Companies House, business directories, media publications, social media, and websites (including your own website if you have one.)

Legal basis for processing:necessary to perform a contract, or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing:our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Our use of automated decision-making and profiling

We do not use automated decision making and profiling on the website.

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular, to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics service, Google Analytics and Facebook uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on)and If you click on an event or products but do not buy or register, legth viewed of our videos. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy http://naomitamayama.com/cookiespolicy. Information collected about you, once collected is anonymised and stored on an aggregate basis.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by leaving cookies tool as it is on our website. The policy is to assume opt-out so you will have to opt-in by clicking the slider to on in our cookie tool. Your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing:To improve our advertising ensuring that our products and services are targeted are individuals who would be interested in them. (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: To ensure content we create and advertise is relevant and shown via targeting to people who would be interested in them.

Use of profiling in marketing emails

We use technologies such as web beacons (small graphic files) in our marketing emails to analyse who opens our emails and what actions they take; delivery rates, open rates and click-throughrates, which our emails achieve. We will only use web beacons and insert any other tracking technologies you use in our emails if you have consented their use in accordance with our cookies policy.

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons)including delivery rates, open rates and click-throughrates, which our emails achieve.

How to object: If you object to the use of beacons and similar technologies contact us via email or our website contact form to inform us.

Legal basis for processing:legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third partiesand any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

Our third-party service providers are located in England Apart from hosting and data storage which are located in USA.Our service providers are located in USA, Kuala Lumpur and UK.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing:legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest relied on:where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing:necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract, or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc., and Facebook

Google and Facebook collects information through our use of Google Analytics and Facebook Pixel on our website.

Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page:

We use Facebook Pixel on our website. Facebook Pixel is a tracking code which allows us to track and monitor the success of advertisements we use on Facebook and to improve the effectiveness of those advertisements by recording information such as the device you used to access our website and the actions you took on our website using cookies. We may also use Facebook Pixel to create retargeting advertisements and custom audiences for our advertisements on Facebook and on our website.

Facebook aggregates data gathered from our use of Facebook Pixel on our website with data it gathers from other sources, in order to improve and target advertisements displayed on its website or via its services, to improve its systems and to provide measurement services to third parties which use Facebook’s advertising services. You can find out more about how Facebook handles information they collect about you and other individuals by accessing their privacy policy, which is available here:https://www.facebook.com/about/privacy.

You can block Facebook Pixel using our cookie control tool: clicking I accept the purposes for which you use advertising cookies in our cookie tool (and sliding on or off the sliders in the cookie panel either by clicking on the C logo in the corner of the site or by clicking the button ‘cookie preferences’ when the cookie tool pops up on the site).

Disconnect for Facebook

You can install a browser add-on tool called ‘Disconnect Facebook pixel and FB tracking’. This will stop Facebook tracking you on third party websites. You can install them too here:

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, independent contractors, and insurers,

Further information on each of these third parties is set out below.

Legal basis for processing:ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Advisors

Occasionally, we obtain advice from advisors, such asaccountants, financial advisors, lawyers. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Third party recipient of information]

Data will be passed onto MOBE if you have registered to attend a LIVE event that naomitamayama.com advertise for the company. Data that is shared; Name, telephone number, email address, and the relevant date and time of the event you wish to attend. This third party is located in Kuala Lumpur. Their privacy policy is; https://mobe.com/privacy-policy/?ho_sub1=listbanner&ho_sub2=list&aff_id=302108

Data is never sold or traded with third-parties.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing:legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s):sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing:compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s):legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing:our legitimate interests(Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information is retained by the third-party hosting that we use A2 Hosting USA, their privacy policy can be found here: https://www.a2hosting.co.uk/about/policies#Privacy-Policy

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Third Party Order Information:The majority of products and services that NaomiTamayama.com promotes are third-party and therefore, the order information is collected and stored by the third parties and not naomitamayama.com.

Correspondence and enquiries:when you make an enquiry or correspond with us for any reason, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further months, after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

the purpose(s)and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);

whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);

whether we have any legal basis to continue to process your information (such as your consent);

how valuable your information is (both now and in the future);

any relevant agreed industry practices on how long information should be retained;

the levels of risk, cost and liability involved with us continuing to hold the information;

how hard it is to ensure that the information can be kept up to date and accurate; and

any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use andaccidental loss or destruction, including:

only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;

using secure servers to store your information

verifying the identity of any individual who requests access to information prior to granting them access to information;

using Secure Sockets Layer (SSL) software to encrypt [any information you submit to us via any forms on our websiteandany payment transactions you make on or via our website

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.[2]

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

E-Newsletter

The information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third-party mailing list provider’s servers. Our third-party mailing list provider is:Aweber. You can access their privacy policy here: https://www.aweber.com/privacy.htm

[Country of storage: USA. This country is not subject to an adequacy decision by the European Commission.

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

[Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.][3]

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to support@naomitamayama.com

to request access to your information and information related to our use and processing of your information;

to request the correction or deletion ofyour information;

to request that we restrict our use of your information;

to receive informationwhich you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file)and the right to have that information transferred to another data controller (including a third-party data controller);

to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and

to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note thatif you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK,the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by sending an email to support@naomitamayama.com.

to object to us using or processing your information where we use or process it in order to carry out a task in the public interestorfor our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and

to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message.

sending an email tosupport@naomitamayama.com, asking that we stop sending you marketing communications or by including the words “OPTOUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: http://naomitamayama.com/cookiespolicy

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it.Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy orintend to use your information for a new purpose or a different purposethan the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information aboutthe change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible thatwe could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to support@naomitamayama.com.

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that theydo not track the user. For information about Do Not Track, please visitwww.allaboutdnt.org

Our Cookie Tool assumes ‘Do NotTrack’ status unless you change the sliders on the tool to the on position.

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.